Comment Text:
To the Commissioners,
I created ElectionBettingOdds.com in 2015, a journalistic resource that aggregates betting odds from both US and overseas prediction markets. The site has been accessed by more than 20 million unique users, highlighting that Americans believe the information generated by prediction markets are valuable and worth their time.
The proposed regulation would reduce the quality of information presented on my site, and throughout journalistic reports on everything from elections to the academy awards.
Your proposal would clearly be in violation of the plain text of the law, as elections and award contests are clearly not "gaming" in any kind of plain-English sense of the word. Try doing a scientific survey and ask people if elections are "gaming."
Further, congress clearly did not intend to prohibit election trading with the law, which was passed at a time when election trading existed on sites like Intrade.com, where it was widely cited in the media, including ABC News, the New York Time, the Wall Street Journal, and many more; if congress had intended to ban election trading with Dodd Frank, they would have said so, rather than banning specifically "terrorism, assassination, war, gaming..." The CFTC risks wasting the time and money of its own lawyers, as well as those of many entrepreneurs, by acting beyond the powers Congress gave it.
Your proposal notes that the CFTC does not have the resources to make a decision about every possible market. I suggest that, instead of solving that by banning election and award markets, as the proposed regulation would do, you solve it by *allowing all* election markets and similar. It also will not require work on your end if everything is legal. Instead, focus your resources on banning the things Congress actually asked to be banned: ("terrorism, assassination, war, gaming...")
Returning to the public interest point, there is widespread interest among the general public in predicting the outcomes of elections, because such information helps people and businesses plan for the future.
Thank you for your time, and I hope you will reconsider this proposed regulation.
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Maxim Lott
Creator, ElectionBettingOdds.com
Executive Producer, Stossel TV
Creator, MaximumTruth.org
Creator, TrackingAI.org
